Attachment Letter

Letter

COMMENT submitted by PanAmSat to L3

Letter

2004-12-01

This document pretains to SES-LIC-20020611-00939 for License on a Satellite Earth Station filing.

IBFS_SESLIC2002061100939_479477

                                    €PanAmSat.

                                                                            ORIGINAL
                                     DR6 "RD
Dessiber 1. 3004                      Satalite and           RECEIVED
                              Rediocommubications Division
Ms. Mariene Dortch, Secretary ‘10m@tonalBureau              DEC — 1 2004
Federal Communications Commission                                    en
The Portals Building                                     mmrxg:m:\::m l
445 12th Street, SW                                            i
Tw—As2s
Washington, D.C. 20554
                       Re: 13 Communications, Interstate Electronics Corporation (IEC)
                       Application for Earth Station Authority
                       File No: SES—L1C—20020611—00939
                       Call Sign: E020160

Dear Ms. Dortch
PanAmSat Corporation (*PanAmSat") received from L3 Communications, Interstate
Electronics Corporation (IEC) ("TEC"), a letter, dated November 1, 2004, together with
information pertaining to the above referenced application. TEC states that we should
reply directly to the FCC on this matter and that the lack of a reply "within thirty calendar
days from the date of this notice" would be construed "as an assent to the grant of IEC‘s
earth station application".

In similar situations, an affidavit is generally the result of an understanding between the
operators of the satellitesinvolved (in this case PanAmSat and Intelsat). However, so far
we have not been contacted by Intelsat with respect to this matter.


In particular, PanAmSat is concerned with the following specific points:


   (i)     TEC states "that the ESVs will operate with a 20.2° pointing accuracy"and
           then goes on to say that "the operator will terminate ESV transmission when
           the antenna goes beyond 20.5°%. These statements lead to the understanding
           that the pointing accuracy is actually 20.5° and the matter needs clarification.


   (ii)    According to the ESV link parameters provided by IEC, it is concluded that
           the input power density to the antenna may exceed by more than 5 dB the

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        value set in 47CIFR. §25.212(c). This fact combined with the pointing
        accuracy problems discussed in () above raise concerns about the potential
        for interference to PanAmSat uplinks.



(ii)   TBC provides a brief description of the antenna system stabilization but
       PanAmSat would like to know more details about the capabilities of such
       stabilization system.

In view of the points discussed above, PanAmSat is concemed about the potentialfor
interference from TEC earth stations to PanAmSat satellites at 95° W and 99° W and,
in the absence of further clarifications and possible adjustments in the application, is
not i a position to agree with the grant of such application.

Respectfully submitted,

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              f
JGseWibuquerque             l
Senior Director, Regulatory Enginccring
PanAmSat
1801 K Street, NW Suite 440
Washington, D.C. 20006
Phone: 202 2924300
e—mail: jolbuquerque@panamsat.com


cc: Tom Murphy, IBC
    Michelle A. McClure, Esq., Irwin, Campbell & Tannenwald, P.C.



Document Created: 2006-01-26 09:29:17
Document Modified: 2006-01-26 09:29:17

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